Jazztel plc v HMRC: High Court ruling in Stamp Taxes GLO

On 3 April 2017, Marcus Smith J delivered judgment in the High Court in Jazztel plc v HMRC [2017] EWHC 677 (Ch), the test case in the Stamp Taxes GLO. The claimant here sought recovery of UK stamp duty reserve tax (SDRT) that it had paid on the issue of shares to clearance houses and in exchange for depository receipts. Under ss 96 and 93 respectively of the Finance Act 1986, such transactions gave rise to a charge to SDRT at a higher rate of 1.5%, as compared with the 0.5% charge that applied to a standard transfer of shares.